CFC rules

CFC rules

The CFC regime imposes a UK tax charge on the UK resident controllers in respect of the profits of certain controlled foreign companies (CFCs). The CFC regime imposes a charge to tax on the UK resident controllers of a non-UK resident company.

Definition of a CFC

A CFC is a company that is:

•
resident outside the UK, and
•
controlled by persons resident in the UK

For more information about:

•
the definition of company and the accounting period of a CFC, see Practice Note: CFC rules—definitions of company and accounting period
•
the meaning of control, see Practice Note CFC rules—definition of legal, economic and accounting control
•
where a controller or CFC is resident, see Practice Note: CFC rules—determining residence of controllers and CFCs.

Exemptions from the CFC rules

Even if a company is found to be a CFC, the CFC regime does not apply if the CFC:

•
has an accounting period that is an exempt period

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